Protecting the environment

Environmental commitment

Our commitment to being a leading energy services provider allows us to meet the growing demand for our services while striving to protect the environment. With the support and approval of senior management, we conduct our business in the context of this commitment to our customers, employees and the communities where we operate. Our approach to environmental stewardship helps guide decision-making across the company.

Core principles of our environmental commitment include:

• Conducting operations in compliance with applicable federal, state and local laws, regulations and standards
• Fostering a culture of compliance through leader engagement and our Open-Door Policy
• Promoting company-wide awareness and employee ownership of environmental stewardship through regular training, leadership communications and availability of educational resources
• Using our Environmental Management System to establish objectives and goals, manage programs and track performance
• Incorporating environmental considerations in the planning, design and execution of engineering, construction, operating and decommissioning practices at our facilities
• Seeking to minimize impacts through project-specific environmental protection strategies and restoring land affected by project construction and facility operations where possible
• Being a responsible neighbor in the communities where we operate
• Prioritizing efficiencies in construction and operation to minimize the use of natural resources and energy sources
• Exploring new technologies to help reduce our methane emissions and overall carbon footprint
• Striving for continuous improvement by working with regulatory agencies, peer operators and industry organizations

Boardwalk’s senior vice president of operations, engineering and construction oversees the implementation of initiatives that support these commitments.

Environmental audit program

We identify strengths and weaknesses, trends and potential threats to the environment and environmental compliance through our environmental audit program.

Internal Environmental Audits:

Our environmental department has dedicated internal environmental coordinators who collaborate with field operations across the company to perform site-specific environmental audits. Findings are summarized and communicated to the field and senior management. Corrective actions may be implement where appropriate, and relevant training is provided to appropriate employees. The implementation of corrective actions is tracked by the OMS and the environmental department. Data is collected in the OMS throughout the year and reviewed to identify areas of improvement. We have an internal audit team that performs compliance audits at field operations locations. These audits review aspects of environmental compliance, including air, water and waste. Audits typically include reviews of record keeping and physical reviews of the facilities.

External Environmental Audits:

‍Our external audit program is similar in scope to our internal audit program. We work closely with third-party firms proficient in federal, state and local regulatory compliance to complement our internal audit program. The frequency and duration of external audits are determined based on business needs and risk assessments. Regulatory authorities and agencies also conduct frequent inspections and audits. Frequency depends on external factors such as regulatory risk matrices, agency staffing and availability.

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Waste minimization

We generate waste during pipeline construction, maintenance and normal operational activities. Typical waste streams include scrap metal, wet and dry spoils, pipeline coating, used oil and other hydrocarbon-containing liquids and sludges.

Waste containers are appropriately labeled, characterized, stored and profiled. Waste is then recycled or disposed of in accordance with applicable federal and state regulations. We seek opportunities to reduce, reuse or recycle during the evaluation process.

Our waste management practices and procedures continue to be documented, tracked and assessed. Our environmental specialists also assist with compliance assurance through routine inspections of on-site waste handling practices. Those findings are documented and promptly addressed with the respective department or location. These measures are paired with comprehensive waste management-related training delivered annually to field-based employees.

Hydrocarbon waste

We manage the majority of our hydrocarbon containing waste materials for reclamation. These materials include pipeline pigging waste, tank sludge, used filters and absorbents, oil and water mixtures, lubrication oil, natural gas condensate and outdated petroleum-containing products. We also recycle waste generated through our operations at corporate offices and field locations, such as paper, plastic, aluminum, mercury vapor lamps and bulbs, mercury switches, mercury thermostats, wet and dry cell batteries, used electronics, and ferrous and non-ferrous metals.

Construction waste

Our construction projects are required to follow an internally developed waste management plan, which highlights project-specific waste handling requirements. We implement soil reuse practices during project work in accordance with federal and state regulations wherever possible. Hydrovac slurries, a combination of soil and water, are a waste derivative of certain maintenance and construction projects. These slurries and other wet and dry spoils are reused on Boardwalk-owned property whenever possible to avoid landfilling or offsite disposition.

Mercury-containing equipment

Our Gulf South and Texas Gas pipeline systems, comprising nearly 94% of our operations, have voluntarily removed mercury-containing gas meters from service, properly disposed of them and replaced them with non-mercury-containing monitoring equipment.

Chemical tracking

We develop and maintain an electronic repository for Safety Data Sheets to streamline the availability of chemical information. The repository can be filtered down to specific operational locations for readily available chemical data. Our Encamp Tier II reporting efforts are annually prepared and submitted through a leading environmental, health and safety digitization and sustainability firm.

Other waste

Other notable waste reduction achievements include:

• Transitioning to handling aerosol cans as a universal waste stream in operational states where possible.
• Recycling or selling used equipment and materials as an alternative to landfill disposal.
• Installing and using natural gas-powered wastewater evaporators, which reduce the amount of wastewater hauled to disposal facilities.

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Spill prevention

We are committed to protecting the environment and the communities where we operate while delivering an energy-efficient resource to our customers. We implement measures to help prevent hydrocarbon spills through management practices, training, regulatory compliance and rigorous internal protocols and procedures.

Bulk quantities of hydrocarbon liquid products such as pipeline condensate, used oil and new oil are stored in above-ground storage tanks at our facilities throughout our operational areas. In compliance with applicable federal and state regulations, we have developed SPCC plans at each qualifying facility, and we conduct regular tank and secondary containment inspections as part of the SPCC plan requirements. We train our employees to follow SPCC regulations and seek to continuously improve our training and response measures through relationships with third-party emergency response companies and active involvement with various organizations such as the SGA. Additionally, each SPCC regulated facility has an SPCC compliance poster that quickly references valuable information such as facility layout, spill response kit locations, appropriate environmental contact information, emergency response information, and a flowchart of the reporting process and conditions.

We have also developed Oil Spill Response Plans and conducted qualified individual training and periodic tabletop spill response drills in partnership with the Bureau of Safety and Environmental Enforcement. We are an associate member of Clean Gulf Associates and partner with Spill Center, Inc. to report and respond to spills that may occur within our system. We regularly review and update our spill reporting, response and cleanup procedures outlined in our EPM.

As part of our tank integrity program, we use the API and Steel Tank Industrial standards and qualified third-party inspectors to inspect the structural integrity of our above-ground storage tanks. These inspections are documented at each facility, and tank inspection schedules are tracked through our above-ground storage tank inventory list. We treat spills during construction using the same procedures and processes we use in our facilities. Our projects utilize industry leading practices, including equipment that provides spill containment. This equipment is conveniently located in vehicles or close to potential spill sites. Our construction managers, contractors and staff are trained on spill awareness, which includes when and how to notify the environmental department for potential agency reporting. Our environmental department is an integral part of our construction projects, providing training on topics such as spill prevention, response and reporting to construction managers and personnel.

Biodiversity protection

Our environmental stewardship strategy includes protecting biodiversity and mitigating risks to the ecosystem. We work to minimize our impact on the ecosystems and habitats where we operate. Fundamental to this approach is a thorough vetting of construction project components and their potential impact on natural resources. Multiple risk assessments are conducted during the conceptual phase of project development efforts to seek to reduce or potentially avoid biodiversity impacts. We use internal specialists to engage with various contractors, consultants and public and private stakeholders about specific environmental conditions that may be present and provide ample time for planning, construction and any necessary mitigation. Our environmental management team remains heavily ingrained in project phases to minimize biodiversity impacts where possible.

Our biodiversity strategy consists of the following stages:

Planning and design

Project development teams review proposed actions based on size, complexity and potential adverse impacts to resources. These teams include internal and contracted engineers, scientists, biologists, logistics and supply chain specialists, planners, regulatory staff and land specialists. Best practices are implemented during the planning and design phases when possible. One example of this is the implementation of a mitigation hierarchy. This includes avoiding sensitive areas, minimizing impacts, rehabilitation and restoration and offsetting ecological/biodiversity-related losses.
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The initial review process is designed to find ways to avoid or minimize impacts to biodiversity priority areas such as:

• Sensitive ecosystems, including critical habitats, high biodiversity areas, threatened and endangered species, migratory birds, floodplains and essential fish habitats.
• Sensitive surface waters, including natural, recreational, wild or scenic areas.

The review process also helps identify:

• Industrial, commercial and residential areas.
• Stakeholder concerns and interests.
• Operational efficiencies and reliability.

Where appropriate, changes to the location, scope or timing of a project may be altered based on the potential impact on any of the following resources:

• Soils, topography and land use.
• Areas of cultural, archaeological or historical significance.
• Wetland and waterbodies, vegetation or wildlife and their habitats.

Construction and execution

We work with internal and external stakeholders, including landowners, to minimize impacts and restore disturbed areas to the extent practicable. This includes engagement with affected parties and regulatory agencies on biodiversity, specific species and land use. We also comply with applicable laws and regulations.

Following the planning and design phase, other construction and mitigative procedures may do the following:

• Use measures to minimize erosion and enhance revegetation.
• Protect water and wetland resources.
• Reduce the amount of time between construction and restoration.
• Preserve and restore topsoil through decompaction.
• Maintain existing drainage and water flow near our projects, including utilizing and repairing drain tiles.
• Utilize horizontal directional drilling technology in sensitive areas.
• Perform timely and adequate spill prevention and response procedures.
• Limit the spread of nuisance and invasive species.
• Use restoration practices that comply with landowner and agency requirements.
• Develop proactive traffic planning and noise minimization.
• Deploy environmental inspectors on construction projects to align with environmental regulations.

Post-construction restoration

Prudent soil and water management during construction is a key component of successfully restoring impacted ecosystems. Proper restoration results in well-vegetated rights-of-way and new habitats for various species that will use herbaceous and shrub or scrub rights-of-way. Additionally, we monitor and rehabilitate areas where restoration is challenged or fails.

Our approach aims to steward the existing biodiversity in the communities where our facilities operate while fostering a culture of pride in the facilities and assets we build and maintain.

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Water conservation

We are committed to managing water consumption, reducing wastewater effluent volumes and disposing of used water so that we can responsibly return as much water to the environment as possible.

We do this by working to help ensure:

• Water returned to the environment meets applicable regulatory standards and requirements.
• Our assets are in areas that are generally not under high water stress or drought conditions.
• Impacts resulting from water usage are reviewed, and we strive to avoid or minimize such impacts.
• Requisite permits and conditions are obtained and adhered to.
• We use current internal construction specifications and industry-leading management practices.
• Product specifications for environmental control devices are met and maintained based on regulatory and industrial standards.

Water and effluent management and compliance practices are integrated from initial design to construction and maintained throughout a facility’s operational lifetime. Specifications are incorporated during detailed engineering design and included in construction bid documents to help ensure contractors complete their work in a way that is consistent with our standards. We also train personnel who install, maintain and repair controls to minimize impacts. Our Environmental Procedures Manual encourages employees to strive to minimize off-site environmental impacts through early-stage project planning, training and continually searching for new and innovative solutions.

Hydrostatic testing, brine production and the development of underground salt dome storage caverns are examples of high-water utilization. Senior management oversees the use and management of water assets. Variances or any non-compliances are presented to senior management for review.

Wastewater management

We manage facility wastewater effluents from operational and sanitary water needs in accordance with applicable permits and conditions. We developed several environmental procedures to assist in wastewater management, including discharging to publicly owned treatment works, and disposing of wastewater, domestic sewage and hydrostatic test discharges offsite. These procedures are utilized by environmental, operations and construction staff to help ensure proper wastewater management and to aid in finding ways to reduce water usage. Environmental procedures are routinely reviewed and updated to reflect current regulatory requirements and industry standards.

Stormwater runoff management

Our existing facilities are designed and maintained to help capture and control stormwater runoff effectively. Proper design and construction of containment ditches and recovery systems are integral to slowing down surface water and stormwater runoff onto adjacent property. Such stormwater controls differ based on site topography and are heavily influenced by federal, state and local regulations. Stormwater management at our facilities is governed by published industry environmental procedures. These procedures assist operations and construction staff with controlling stormwater discharge and preventing adverse impacts on bodies of water.

Stormwater pollution and spill prevention

We seek to comply with SWPP, SPCC and other applicable water management regulations where required. New construction and runoff from existing facilities may impact water resources and water quality. We implement an SPCC Plan for regulated materials stored in above-ground storage containers, containers holding oil with volumes of 55 gallons or more and oil-filled equipment, including engine crankcases and hydraulic-fluid-driven equipment.

We implement the following measures in an effort to prevent harmful discharges to the environment:

• Ensuring appropriately sized containment for above ground storage tanks, including double-walled tanks, secondary containment installed around single-walled tanks and appropriately sized spill containments under drums or temporary oil containers.
• Storing liquids inside buildings, when possible, to prevent contact with rainwater.
• Placing spill kits near regulated liquid storage areas to contain and mitigate unexpected releases.
• Requiring outlet valves not in use on regulated liquid storage tanks to be closed and locked.
• Requiring regulated liquid storage tanks with external secondary containments to have the containment drain valve in the closed position and locked when not actively draining stormwater.

Hydrostatic testing

Our environmental department oversees water use for hydrostatic testing in construction and operations activities. We have a hydrostatic water discharge information checklist to identify needs and requirements for pipeline and facility testing. Whenever possible, we attempt to reuse water between pipeline sections to minimize the amount of water used. Following hydrostatic tests, we submit representative samples of hydrotested water to certified laboratories to help ensure the water returned to the watershed meets all applicable permit requirements.

We permit, track and oversee discharges per federal or state permit conditions and company policies, including our Pipeline Hydrostatic Testing Procedures Handbook. This handbook is reviewed and updated to reflect regulatory changes or new permit conditions. The environmental department uses the information to complete required notices through the EPA’s National Pollutant Discharge Elimination System's Discharge Monitoring Report.

We began tracking water used for hydrostatic testing of pipeline systems and tanks in 2023. This tracking tool includes measuring water withdrawn, reused and returned to the environment through a permitted outfall or disposed of through a third-party vendor.

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